The way I understand this situation is:
If he already gets paid via a marketplace such as Upwork for work, could he shut the upwork account and start new one on the name of his Panama company with a Cyprus bank account to get paid by his clients. Then bill the Panama company for consultation fees and get the money in France Via Upwork middleman. However, he would still remain the UBO of the offshore company. Is this why he can't optimize his taxes?
Now, if he had a Panama resident visa since it is easy to get one for Panama friendly nations list, his︀ bank account would show him as the Panama resident even if he lived in France,︁ as there would be no residency requirements in Panama. Would tax optimization still be a︂ problem?